Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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AT dismissed appeals challenging the Additional Director of Enforcement's order dropping FEMA charges against respondent companies. The charges stemmed from DRI's Show-Cause Notice under Customs Act alleging customs duty evasion through value suppression of export goods. AT found the Fe content declaration was properly based on government-accredited lab reports, following prescribed procedures for independent certification and sample testing. The pricing variation fell within acceptable tolerance range for arm's length transactions. With the underlying customs case nullified and no evidence of lab report manipulation, AT upheld the original order dropping FEMA charges, noting that challenging government lab reports requires demonstrating they are palpably wrong, citing established precedent.
AT dismissed appeals challenging the Additional Director of Enforcement's order dropping FEMA charges against respondent companies. The charges stemmed from DRI's Show-Cause Notice under Customs Act alleging customs duty evasion through value suppression of export goods. AT found the Fe content declaration was properly based on government-accredited lab reports, following prescribed procedures for independent certification and sample testing. The pricing variation fell within acceptable tolerance range for arm's length transactions. With the underlying customs case nullified and no evidence of lab report manipulation, AT upheld the original order dropping FEMA charges, noting that challenging government lab reports requires demonstrating they are palpably wrong, citing established precedent.
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